Procedure - Network Adequacy and Timely Access

This replaces BHSD Service Access policy 412-404 and SUTS P&P 2,3, and 4​​.

​Responsible Party

Action Required ​

Call​ Center/Gateway Staff

Call Center staff operate the required 24/7 access phone line for individuals or their representatives seeking access to behavioral health services. The Call Center staff conduct and document a screening over the phone that consists of Gateway Referral for Services to assess the individual for acuity risk and to determine best level of follow up behavioral health care needed. All calls are logged on the Cisco Telephone System. If needed, language ​translation is provided through the Language Services of Santa Clara County Health and Hospital System. The Call Center Supervisor monitors and tracks the call log entries to determine compliance to timely access standards for behavioral health services. The results are tabulated and displayed for review by the QAPI program data manager and presented to the BHQIC on a bimonthly basis.​

Community-Based Organization and County Inpatient, Crisis Stabilization, Mobile Crisis Units​

Ensure the availability of urgent and emergent behavioral health services and coordination of care with outpatient providers for continuity and coordination of care. Have adequate 24/7 coverage.​  Where applicable and available BHSD will request Alternative Access Standards and follow requirements that are listed in the MHSUDS Information Notice No.: 18-011 Federal Network Adequacy Standards for Mental Health Plans (MHPS) and Drug Medi-Cal Organized Delivery System (DMC-ODS) Pilot Counties.​

Community-Based Organizations and County Outpatient Providers

Ensure the availability of follow-up services and ongoing treatment services. Conduct a full assessment and intake. Have coverage arranged when a staff member is out of the office on leave through a range of processes including communication, assignment of care responsibility, and mechanisms to cover urgent and time-sensitive issues.​

All providers

  1. ​​​Have 24/7 contact mechanisms in place.

  2. Screen individuals who walk-in or phone-in for risk and acuity.

  3. Have adequate clinical staff to respond to urgent and emergent requests.

  4. Prioritize and serve the most acute clients first.

  5. Link the individual to more acute care like a mobile crisis, crisis stabilization units (CSU), or other emergency care if necessary

  6. Fully complete the Timely Access Log required fields for all clients seeking urgent, emergent, or routine care. (In the electronic health record system).

The log shall contain the name of the beneficiary
Whether the request was made via telephone, in writing, or in person.
Request Date and time
Triage or screening date/time

First Offered Date 
Date of occurrence​ 

  1. Will meet timely access standards based on the acuity of the individual, managed care timelines, and modality of services offered.

  2. Send an adverse benefit determination to enrollee and Call Center if unable to meet timely access standards.

  3. Submit Quarterly timely access information to BHSD QA and internal QAPI programs.

  4. Address corrective action plans for timely access​

To demonstrate network adequacy​:


  1. Providers are required to maintain accurate records of the beneficiary’s physical address, address they prefer for use with service location, with ZIP codes, and the physical address of service location.

  2. Providers will ask at the point of service, “Is this the preferred location of service?”

  3. As needed, the Provider will document exceptions and send them to BHSD.​

QI Committee

​  On an annual basis, documented in the QAPI Work Plan, will set goals for the following:​

  1. Timeliness of routine mental health appointments

  2. Timeliness of services for urgent conditions

  3. Access to after-hours care

  4. Responsiveness of the 24-hour toll-free telephone number.

  Reviews reports of timely access from the Call Center and addresses improvement opportunities.​

 BHSD ​ ​​

  1. ​BHSD will generate reports based on time and distance from physical addresses of beneficiary’s home to service location, including specific submission requirements and key due dates, responsible party, and within specific timeframes, consistent with the guidance in MHSUDS Information Notice No.: 18-011 Federal Network Adequacy Standards for Mental Health Plans (MHPS) and Drug Medi-Cal Organized Delivery System (DMC-ODS) Pilot Counties

  2. BHSD will follow DHCS guidelines for network adequacy standards for anticipated enrollment and expected utilization of routine behavioral health services, as stated in MHSUDS Information Notice No.: 18-011 Federal Network Adequacy Standards for Mental Health Plans (MHPS) and Drug Medi-Cal Organized Delivery System (DMC-ODS) Pilot Counties.

  1. ​ ​Monitor compliance with network adequacy standards. Quarterly NACT data submissions for MHP providers and annual NACT data submissions for DMC-ODS providers.

  2. BHSD will use a geographic software program that determines the distance between a participant and the defined provider. They will compare the database of providers with the database of participants and pinpoint the distance between providers and participants according to mileage or driving time

  3.  BHSD will keep a log of exception requests and documentation. Annually, it is the standard practice of SCC BHSD to review and identify gaps and adjust contracts accordingly. All exceptions made for network adequacy standards regarding geographic location will be documented.

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